H.R. 5349
TAS Act
Sponsor: Nathaniel Moran
1 cosponsor
Official summary
Written by the Congressional Research Service.
Tax Court Improvement Act
This bill expands the authority of the U.S. Tax Court to issue subpoenas, authorizes the Tax Court to extend certain petition deadlines, and makes other changes related to Tax Court procedures.
The bill authorizes the Tax Court to issue subpoenas compelling the production of documents and other items from a litigant or witness for evidentiary or discovery purposes (whether or not it is in connection with a scheduled hearing). (Under current law, the Tax Court may issue subpoenas only to compel the attendance and testimony of witnesses and the production of evidence at a scheduled hearing or deposition.)
The bill authorizes the Tax Court to extend (or toll) the deadline to file a Tax Court petition contesting an Internal Revenue Service (IRS) deficiency notice if it is equitable to do so (known as equitable tolling). Further, under the bill, the dismissal of a petition contesting an IRS deficiency notice because the petition is not filed before the deadline and equitable tolling is denied is not treated as a decision of the Tax Court. This allows a subsequent claim to be filed in U.S. district court if certain conditions are met.
The bill also
- expands the type of Tax Court proceedings for which special trial judges may be appointed,
- authorizes Tax Court special trial judges to impose fines up to $5,000 and up to 30 days in jail for contempt of court, and
- requires Tax Court judges and special trial judges to recuse themselves in certain circumstances.
Text of the bill
I Tax Administration and Customer Service
Where this section came from
Not in the first version (Introduced in House, Sep 15).
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Sep 30, 2026 · Engrossed Amendment Senate S.Amdt. 6848: To amend the title. Official page › S.Amdt. 6847: In the nature of a substitute. Official page ›
(a) In general. Not later than January 1 of the first calendar year beginning more than 18 months after the date of enactment of this Act, the Secretary shall make available a website or mobile application which allows any taxpayer (including any taxpayer residing outside of the United States) the ability to—
(1) in a manner consistent with any applicable limitations under section 6103 of the Internal Revenue Code of 1986, view any return (as defined in section 6103(b)(1) of the Internal Revenue Code of 1986), document, notice, or letter (with the exception of any educational item which has no legal effect) which, during the applicable period (as defined in subsection (d)), has been—
(A) sent by the Internal Revenue Service to such taxpayer, or
(B) filed with (or, in the case of any document not required to be filed, sent to) the Internal Revenue Service—
(i) by such taxpayer,
(ii) by a person described in subsection (c) of section 6103 of the Internal Revenue Code of 1986 with respect to such taxpayer, or
(iii) with respect to such taxpayer in a manner described in subsection (e) of such section,
(2) with respect to any document, notice, or letter sent to such taxpayer by the Internal Revenue Service, respond to such document, notice, or letter by uploading or otherwise transmitting the taxpayer's response through the website or mobile application, and
(3) in the case of— permit such representative, preparer, or agent, to the extent authorized by the taxpayer, to access the information described in paragraph (1) or transmit any information described in paragraph (2).
(A) any representative of such taxpayer who is authorized to practice before the Department of the Treasury pursuant to section 330 of title 31, United States Code,
(B) any tax return preparer (as defined in section 7701(a)(36) of the Internal Revenue Code of 1986) with an identifying number (as described in section 6109(a)(4) of such Code), or
(C) any qualified reporting agent,
(b) Availability for viewing. With respect to any return, document, notice, or letter described in paragraph (1) of subsection (a), such return, document, notice, or letter shall be made available for viewing by the taxpayer (or, pursuant to paragraph (3) of such subsection, any representative, tax return preparer, or qualified reporting agent authorized by the taxpayer) as soon as is practicable and within such periods as are established pursuant to regulations prescribed by the Secretary.
(c) Access to multiple accounts by representative, preparer, or agent. For purposes of subsection (a)(3), the website or mobile application shall allow a representative, tax return preparer, or qualified reporting agent to be able to access information for multiple taxpayers who have provided permission under such subsection without any requirement to individually and separately access the account of each such taxpayer.
(d) Applicable period
(1) In general. Subject to paragraph (2), for purposes of subsection (a)(1), the term applicable period means the preceding 6-year period.
(2) Prospective application. The term applicable period shall not include any years ending before the date of enactment of this Act.
(e) Qualified reporting agent
(1) In general. For purposes of this section, the term qualified reporting agent means a person—
(A) which is properly authorized as an agent to sign and file employment tax returns, make related payments and deposits, and perform such other acts on behalf of a taxpayer under procedures set forth by the Secretary,
(B) which has met such requirements as may be established by the Secretary, and
(C) for which authorization has not been revoked or suspended by the Secretary pursuant to procedures established by the Secretary.
(2) Employment tax return. For purposes of paragraph (1)(A), the term employment tax return means—
(A) any return required to be filed by an employer to report the obligations of the employer and its employees under section 3101, 3111, 3301, or 3402 of the Internal Revenue Code of 1986, and
(B) such other returns as designated by the Secretary.
(f) Preventing unauthorized disclosure of return information by persons designated by taxpayers. Not later than January 1 of the first calendar year beginning more than 18 months after the date of enactment of this Act, the Secretary shall—
(1) establish a program to investigate and address—
(A) any access, use, or disclosure of return information (as defined in section 6103(b) of the Internal Revenue Code of 1986) by any person which is in excess of the authorization permitted to such person pursuant to subsection (a)(3), and
(B) any related misconduct, and
(2) annually publish, on the public website of the Internal Revenue Service, the actions undertaken pursuant to the program described in paragraph (1), such as the number of complaints investigated, the number of persons whose access was revoked, and other relevant statistical data.
(g) Focus groups. For purposes of subsection (a), prior to the date that the website or mobile application described in such subsection is made available, the Secretary shall conduct focus groups with taxpayers and tax professionals to ensure that any amounts appropriated or otherwise made available for such purposes are expended in an appropriate manner.
II American Citizens Abroad
III Judicial Review
IV Office of the Taxpayer Advocate
V Tax Return Preparers
VI Appeals
VII Whistleblowers
VIII Hostages
IX Small Businesses
X Miscellaneous